Land Grab Gone Wrong: MP High Court Tosses 'Counterblast' FIR Over Bogus Conspiracy Claims

In a decisive ruling on March 31, 2026, the High Court of Madhya Pradesh at Jabalpur , presided over by Justice B. P. Sharma , quashed a trial court order directing an FIR against Pawan Mittal and others. The petitioners, linked to land demarcation favoring M/s Ankit Tracam Pvt. Ltd. , escaped charges of forgery, cheating, and conspiracy filed by the legal heirs of late Narendra Jain. The court slammed the proceedings as an abuse of law stemming from a pure civil land tussle in Katni district.

Demarcation Drama: From Encroachment Bust to Courtroom Clash

The saga unfolded over disputed land in Katni, where Ankit Tracam Pvt. Ltd. invoked Section 129 of the M.P. Land Revenue Code for demarcation. Revenue authorities spotted encroachments by the Jains' heirs (respondents 2-5), leading to removal orders under Section 250 and possession restoration to the company on July 15, 2020.

The Jains challenged this, but appeals failed until a 2021 writ petition ( W.P. No. 11015/2021 ) exposed a glitch: proceedings listed deceased Narendra Jain as present. The High Court set them aside on that narrow ground, ordering probes into erring officials. Fresh demarcation in October-November 2022, post-notices, again deemed the Jains encroachers.

Enter the criminal twist. Petitioner Pawan Mittal filed an FIR against the Jains in 2021. Alleging retaliation, the Jains complained to Magistrate, Katni, accusing petitioners and revenue officials of IPC offences like Sections 166, 167, 182, 193, 420, 467, 120-B —claiming fake records showed Jain alive. On May 25, 2024, under Section 156(3) CrPC (now BNSS), the magistrate ordered FIR No. 321/2024 at Sleemanabad police station, prompting petitioners' plea under Section 528 BNSS (old 482 CrPC).

Petitioners' Defense: 'We're Not the Scribes of Forgery'

Petitioners' counsel, Anuj Agarwal, argued the dispute was civil, rooted in revenue reports they never signed or influenced. No overt acts tied them to alleged fakes, like noting Jain's presence; that was officials' domain. Bald claims lacked specifics, mens rea, or conspiracy proof. Post-2022 demarcation reaffirmed encroachments sans their input. Citing Supreme Court precedents like Sheila Sebastian v. R. Jawaharaj (AIR 2018 SC 2434) on vague allegations and Mohd. Ibrahim v. State of Bihar ((2009) 8 SCC 751), plus local cases, they branded the FIR a "counterblast" miscarriage.

Respondents Push Back: 'Cognizable Crimes Demand Probe'

Respondents' advocate Aditya Jain and state prosecutor Jitendra Shrivastava countered that the complaint revealed serious fabrication, cheating, and conspiracy needing police probe. The magistrate, post Section 200 CrPC inquiry, rightly invoked Section 156(3) ; High Court shouldn't preemptively dissect facts at this stage.

Court's Razor-Sharp Reasoning: No Minds Met, No Crime Made

Justice Sharma dissected the complaint: petitioners weren't report authors, signatories, or informants on Jain's status. Demarcation was official revenue work; blaming beneficiaries for officials' errors doesn't stick. No evidence of "meeting of minds" for conspiracy under IPC 120-B .

Precedents reinforced: Vague, omnibus pleas fail quashing tests ( Sheila Sebastian ), especially sans prima facie case ( Mohd. Ibrahim ). Local rulings like Usha Ajay Singh v. State of M.P. (2023) and Asha Shivhare v. Pradeep Shivhare (2025) echoed abuse in civil-criminal crossovers.

The magistrate's order? "Mechanical," sans ingredient check. As media reports noted, this underscores how land revenue probes can't spawn conspiracy charges on thin air.

Key Observations

"There is absolutely no material on record to establish any meeting of minds or agreement so as to constitute an offence of criminal conspiracy. The essential ingredient of mens rea is conspicuously absent."

"Mere allegation that the petitioners may have derived some indirect advantage from the demarcation proceedings cannot, in law, be sufficient to infer their involvement in a criminal conspiracy, particularly in the absence of any cogent evidence."

"The allegation that a deceased person was shown as present in the demarcation report, even if accepted on its face, pertains to the conduct of the revenue officials who prepared such report, and not to the petitioners."

"A perusal of the order passed by the learned Magistrate under Section 156(3) Cr.P.C. reveals that the same has been passed without proper application of judicial mind."

FIR Annihilated: Clean Slate for Petitioners, Warning for Future Filings

The court allowed the petition outright: "The order dated 25.05.2024... and subsequently FIR No.321/2024... along with all subsequent proceedings arising therefrom, are hereby quashed against the present petitioners only ."

This shields innocents from retaliatory FIRs in land rows, mandating magistrates scrutinize complaints before FIR nods. For revenue-driven disputes, it signals: Prove active criminality, or courts will quash. A win against "mala fide" weaponization, potentially easing probes for companies like Ankit Tracam.

Case: Pawan Mittal & Ors. v. State of M.P. & Ors. [MCRC-37442-2024]